We are committed to protecting your privacy. This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how John Weygang Optometrists LLP uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us at our head office, which is at: 39 Hucclecote Rd, Hucclecote, Gloucester, GL3 3TL.
2. What is John Weygang Optometrists LLP?
John Weygang Optometrists LLP - which we will call JWO in this document - is a Limited Liability Partnership of Optometrists, working around Gloucester. We have been in business since 1971 (as both John Weygang & Partners and JWO). We have 5 Optical Practices in the area (at Abbeymead, Churchdown, Clarence St (City Centre), Hucclecote and Quedgeley).
3. Explaining the legal basis for data processing
The law on Data Protection is changing on 25th May 2018. All data processing after that date will be carried out under the General Data Protection Regulation (GDPR).
Under GDPR there are a number of different reasons for which a business may collect and process your personal data. At JWO, our legal reasons for data processing are:
- The purposes of Health Care
In order to book appointments, carry out sight tests, undertake retinal photography and other optically related tasks, we will need to take your personal data
- Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations to the National Health Service (NHS). We also collect data under this heading with regard to our dealings with our staff, where processing is necessary to carry out our obligations as an employer, for example for payroll purposes.
- Legal compliance
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting JWO to law enforcement.
- Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your purchase history to send you, or make available, personalised offers.
We may also use your address details to send you direct marketing information by post, SMS or e-mail, telling you about products and services that we think might interest you.
Data is also collected under this heading for some financial transactions, for instance Direct Debit details.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
4. When do we collect personal data?
- When you visit our website, and use your data to request appointments or Ask the Expert
- When you book an appointment with us
- If you order goods (such as contact lenses) or services (such as a Domiciliary Visit) from us, either in a Practice or over the telephone
- If you engage with us on social media
- If you contact us by any means with queries, complaints etc.
- If you ask one of our Partners to email you information about a product or service (such as a query about Colorimetry assessments or Workplace eye tests)
- If you enter prize draws or competitions.
- If you choose to complete any surveys we send you.
- If you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
- When you fill in any forms.
- When you’ve given a third party permission to share with us the information they hold about you (for instance with another Optician or an Insurance Company)
- Some of our Practices have CCTV systems operated for the security of both customers and JWO staff. These systems may record your image during your visit.
- If you apply for employment with us
5. What sort of personal data do we collect?
If you book an appointment with us: your name, gender, date of birth, home address, contact telephone number and Doctor's information.
When you come if for the appointment we will check the above information and will ask if you have mobile telephone numbers or e-mail addresses you would be happy for us to use to contact you with. We may also ask, as required by our contracts with the NHS, for your National Insurance number and details of any social benefits (such as Pension Credit) that you may receive. We may ask for some general eye-related information about your health, such as are you Diabetic or do you have a close family history of Glaucoma.
During the examination our registered health care professionals will ask more detailed information about your health.
If you sign Direct Debit forms (such as for contact lenses) or are employed by us, we will require banking information.
If you are employed by us, we will require your National Insurance number and a copy of your passport (if you have one).
6. Details of your interactions with us
- We may collect notes from our conversations with you, details of any complaints, comments you make, details of purchases you made, brands you show interest in and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your Practice preferences, for example, which of our Practices you prefer to visit
- We may look at details of your visits to our website and which site you came from to ours
- Personal details which help us to recommend items of interest. For example you might tell us of a particular hobby, such as shooting, which we'll use to recommend specialised spectacles.
- We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your optical experience with us. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit one of our Practices.
- Your social media user name, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
7. How and why do we use your personal data?
We want to give you the best possible eye care at JWO. One way to achieve that is to get the fullest picture we can of who you are by combining the data we have about you. We then use this to offer you the best all round service in terms of examination and refraction as well as offering promotions, products and services that are most likely to interest, and be of specific benefit to you.
The data privacy law allows this as part of our legitimate interest in understanding our patients and providing the highest levels of service to them.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are your rights?’ section below.
But please remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
- To carry out thorough eye examinations and contact lens checks. We will do this on the basis of legitimate interest and the purposes of health care.
- To contact additional health care professionals with the findings of our examinations, or to query historic health related issues. We will do this on the basis of legitimate interest and the purposes of health care.
- To process any orders that you make by using either our website or in the Practice. If we don’t collect your personal data during the ordering/payment elements of the transaction, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on. We will do this on the basis of our legitimate business interests and contractual obligations to you.
- To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond thoroughly. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. We may also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We will do this on the basis of our legitimate business interests and contractual obligations to you.
- To protect our customers, premises, assets and staff from crime, we operate CCTV systems in some of our practices which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our Patients from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities. We will do this on the basis of our legitimate business interests.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. We will do this on the basis of our legitimate business, but of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post, SMS or e-mail in relation to reminders to book appointments, updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post, SMS or e-mail at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. These service messages will not include any promotional content and do not require prior consent when sent by post, email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering, we will do this on the basis of our legitimate business interests and contractual obligations to you.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time.
- To process your booking/appointment requests. Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we’d be unable to fulfil your request.
- Combining your data for marketing. We will do this on the basis of our legitimate business interests and contractual obligations to you. We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as other Opticians, hobby groups, sporting clubs etc.
8. How do we protect your data?
We know how much data security matters to all our patients, staff and contractors. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our website.
Access to your personal data is password-protected and subject to multi factor authentication. Sensitive data is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and to identify ways to further strengthen security.
Paper records are kept securely.
All registered staff comply with GOS standards, which ensures they respect and understand patient confidentiality.
All anti-virus software and other software is kept up to date.
9. How long will we keep personal data for?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
The NHS specify 7 years or, in the case of children under 18, until their 25th birthday. College of Optometrists guidance says it is best practice for all records to be kept for 10 years after the patient's last visit, so that's what we do at JWO.
At the end of that retention period, your data will either be deleted completely (for electronic records) or shredded (for paper records).
Staff records are kept for 10 years after staff have left. Personal data held on non-interviewed applicants will be destroyed at the end of the interview process. Interviewed but unsuccessful candidates, if considered worthy, will be contacted and asked to reply in writing if they wish their information to be kept on file for 12 months from the date of their interview.
When you place an order for spectacles or contact lenses, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
10. Who do we share personal data with?
We sometimes share your personal data with trusted third parties. For example, other health care professionals, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as glazing laboratories, contact lens manufacturers, delivery couriers.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- If we run a joint promotional event with another company and you agree to receive direct communications from them.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell JWO and this may involve the transfer of the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
- For further information please contact our Data Protection Officer.
11. Where can your personal data be processed?
Your data can be processed at any of the JWO Practices in Gloucester.
12. What are your rights over your personal data?
Under the GDPR, you have the following rights:
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- The right to erasure of your data or “the right to be forgotten”. But this only applies when there is no compelling reason for continued processing. It is therefore NOT applicable where there is a duty to keep accurate records for legal or contractual purposes.
You have the right to request a copy of any information about you that JWO holds at any time, and also to have that information corrected if it is inaccurate. JWO must reply to you within one month of receiving the request. We will also need to ensure that we have obtained proof of identity so there is no risk of disclosure to another party. To ask for your information, please contact Data Protection Officer, John Weygang Optometrists LLP, 39 Hucclecote Rd, Hucclecote, Gloucester, GL3 3TL. Or contact us at firstname.lastname@example.org. Or ring us on 01452 372323.